EPR Corner: Featuring Q&A from the RCA’s Webinar on June 22
EPR Corner: Featuring Q&A from the RCA’s Webinar on June 22
The Recycling Council of Alberta will bring you a monthly feature on Alberta’s transition to Extended Producer Responsibility (EPR). We will feature FAQs we have received and key information about what is happening during the transition to EPR.
This month we are highlighting questions and answers from the EPR Transition Webinar Series – Examining the role of oversight bodies and producer responsibility organizations. As part of the transition to extended producer responsibility (EPR), it’s important that stakeholders are informed about the roles of different organizations; specifically the differences between the oversight and operation of the EPR system. The presenting organizations included the named oversight body in Alberta, Alberta Recycling Management Authority (ARMA), and three producer responsibility organizations (PROs) that operate programs across the country – Circular Materials, Product Care and Call2Recycle.
Producer responsibility organizations (PROs) are selected by the producers of products and packaging to help meet their obligations under EPR regulations. Services they may provide include collection, management, promotion, education and reporting.
The oversight body will ensure that producers are meeting their obligations and reporting to the Province.
The RCA recorded the session. If you’re an RCA member, please reach out and we will send you the link.
Q&A from the session:
Q: What is the difference between ARMA as it exists now and ARMA as the EPR oversight body?
- A: ARMA can be looked at as an organization that now has two separate and distinct business lines. ARMA will continue to operate the stewardship programs for electronics, paint, tires, and used oil as they always have, being responsible to manage and operate the programs, educating the public about recycling these materials. As the named oversight body in the EPR regulation, ARMA has established a separate department for its role as the EPR oversight body with a new executive director, Dr. Gabrielle Betts. ARMA’s role as the oversight body is to develop bylaws, policies, and processes that outline details and requirements related to registration, reporting, auditing, dispute resolution process, thresholds for exemption, and compliance matters.
- Completing consultations with Alberta Environment and Protected Areas (EPA) in the summer.
- EPR Bylaw ratification and governance transition by Sept. 2023
- Completion of the Registry for producers with registrations to follow Fall of 2023.
- April 1, 2024 – producer verification of collection
- April 1, 2025 – Phase 1 PPP launch, HSP launch
- October 30, 2026- Phase 2 launch (multifamily)
Q: What is the relationship between the PROs and municipalities?
A: The relationship should be collaborative and iterative. Circular Materials has set up municipality working groups in other provinces that have met monthly to keep the lines of communication open. Sharing all the information at the same time with all groups allows for the sharing of questions and answers.
Q: How do producer responsibility organizations (PROs) interact with service providers?
A: Under the EPR regulation, producers are responsible to set up a system to recycle products and follow the requirements set out in the regulation. In Alberta’s case, this applies to single-use products, packaging and printed paper products (PPP) and hazardous and special products (HSP) starting April 1, 2025. Producers (often through PROs) then work with service providers (waste management companies or municipalities) to deliver the services.
Q: How will contracts change with service providers?
A: When municipalities act as a service provider to the PRO then there may be the need to align contracts with existing service providers. There are some benefits to having standardized contracts across the province in consistency for service providers. The existing standards or operations, such as weekly or bi-weekly collection, will generally be maintained.
Q: What is the relationship with the recyclers?
A: Product Care has already reached out to processors and recyclers. Recyclers are essential because reporting requirements need to be set in collaboration. Call2Recycle says that recyclers are vital partners and conversations need to be had on how to collaborate in the future. Circular Materials states that their mandate is to return the material to their producers, so they have strong relationships with recyclers to achieve circular economy goals.
Q: What happens to existing municipal infrastructure during the transition to EPR (i.e., bins and MRFs)?
A: There won’t be a lot of time for the transition, so wherever possible producers want to leverage existing assets. In Ontario and BC, PROs tried to utilize existing facilities. For things like bins, it may depend on who the contractor is, but PROs will look to reach reasonable business arrangements and that will be determined within the next two years as part of implementation.
Q: How will the roll-out work?
A: PROs want to have a consistent material list across the province, consistent communications to make it easy for residents and reduce contamination, and there will be detailed discussions with municipalities as part of implementation.
In terms of depot collection, PROs want to avoid disruption with existing services. There could be a combination of collection mechanisms that allows for the differentiation between program and non-program material, or a separate sortation done after the material leaves the depot with the material accounted for at that time.
Q: Who is enforcing the regulation, ARMA or the government?
A: For the most part ARMA will be dealing with items within the Bylaws – failure to not pay, failure to not report etc. They have the ability to assess fees as a penalty, with the last resort to de-regulate a producer.
Q: What is a verification of collection?
A: A PRO will share the info on plans for the operational side of collection and have to demonstrate to the oversight body how they will meet those requirements.
Q: How do you expect municipalities to sign up or register?
A: The details and process are still being developed, but the municipality will likely have to provide information such as the total households, population, calculated tonnes, and current service levels. ARMA is working on the registration process and will provide municipalities with further details as they are finalized, as well as notifying on other engagement opportunities.
Q: How will Customer service experience/ complaints management work province-wide? Is that at Municipal level or PRO?
A: If the municipality continues to be the service provider, then they would be the contact. If it’s a contractor, then the contractor would answer those questions. The PROs also try to have a call-in line for everyone to use to help address concerns.
We hope this helps answer some of your questions about EPR. Further questions can be shared with the RCA: firstname.lastname@example.org.